Storage facilities for liquid cargo are not clearing and forwarding services when agency functions are absent.

Providing only jetty access and storage facilities for liquid cargo, without handling customs formalities, despatch orders, transport arrangements or commission-based agency functions, does not amount to clearing and forwarding activity under the governing circular. Such services are treated as storage-related services rather than clearing and forwarding operations. On that basis, the assessee was not a clearing and forwarding agent for the relevant period and was not liable to obtain service tax registration on that footing.

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Issues: Whether providing jetty access and storage facilities for liquid cargo rendered the assessee a clearing and forwarding agent liable to obtain registration and pay service tax under the Finance Act, 1994.

Analysis: The governing circular clarified that agencies supplying only storage facility for liquid cargo, charging rent for storage, and not handling customs formalities, despatch orders, transport arrangements, or commission-based agency functions do not perform clearing and forwarding operations. Such activity is to be treated as storage-related service and not as clearing and forwarding. The assessee's activity fell within this classification for the relevant period.

Conclusion: The assessee was not a clearing and forwarding agent for the relevant period and was not liable to obtain registration for service tax on that basis.

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